This privacy policy (the "Privacy Policy") governs how Tenzing Partners S.A., a public limited company under Luxembourg law, established and having its registered office at 1A, Rue Henri Pensis, L-2322 Luxembourg, Grand Duchy of Luxembourg, and registered with the Luxembourg Trade and Companies Register, section B under number 128590 ("TENZING"), processes personal data collected in connection with the website vendio.market (the "Platform") as the data controller.

1. Compliance with Data Protection Legislation

TENZING is committed to complying with the laws and regulations governing the processing of personal data, including, but not limited to, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and any other applicable national laws or regulations governing the processing of personal data.

2. Who Are the Data Subjects?

The Platform is a tool reserved for professionals, excluding any consumers. It facilitates connections between professionals seeking to sell their business and professionals looking to acquire a business, allowing each User to publish the main information about the business they want to buy or sell. The data subjects, i.e., the individuals whose personal data is collected by TENZING, are:

• "VENDIO": Refers to the online Platform and the services offered there.
• "User": Refers to any professional accessing or using VENDIO.
• "Seller": Refers to the professional, either a natural or legal person, offering a business for sale or for lease management on VENDIO.
• "Buyer": Refers to the professional, either a natural or legal person, expressing interest in buying or leasing a business presented on VENDIO.

3. What Personal Data Does VENDIO Collect and Why?

• Identification: Includes the User's name, first name, and the username chosen on the Platform when creating a User Account (the "User Account"). This information is necessary to offer services through the Platform. TENZING may pseudonymize User identification to enhance data security.
• Contact Information: At a minimum, this includes the User's email address but may also include their postal address and phone number, depending on the communication channel chosen. Providing a phone number is mandatory. This data is used to respond to User requests, send marketing communications, and provide necessary information for Platform services.
• Message Content: Users may contact TENZING via contact@vendio.market for additional information or to file complaints.
• Content and Metadata: Refers to operations performed on the Platform, including data flows generated by User activities. While generally not used by TENZING, some elements may be used to refine User profiles and measure project progress.
• Technical Information: Includes browser type, language settings, country and time zone, device type, hardware model, operating system, and unique identifiers. These data are used to ensure optimal use of the Platform and to personalize the experience.
• Backups: Backups are implemented to ensure data availability in case of a physical or technical incident. These backups are maintained until overwritten by new ones.

4. Communications Marketing

VENDIO sends informational and commercial emails ("Marketing Communications") to individuals whose electronic contact details have been obtained through the Platform services unless they objected during data collection. Types of Marketing Communications:

1. Offer Information: Marketing offers and updates on offer conditions.
2. VENDIO Newsletter: Information on Platform Buyers and Sellers.
3. Platform Updates: Notifications about new features, products, or services.
4. Events: Communications about events organized by VENDIO.

5. Use of Social Media

Personal data collected through social media may be processed by VENDIO for marketing purposes and to enhance its public image. VENDIO acts as a joint controller with social networks when their logos are present on the Platform. For more information on personal data processing on different social networks, refer to the relevant privacy policies, such as LinkedIn: LinkedIn Privacy Policy

6. Use of Cookies

VENDIO uses cookies to make the Platform more user-friendly and to tailor it to User interests. Cookies help improve future User activities and provide insights for Platform enhancements. Certain technical cookies do not require User consent, while others do. VENDIO seeks User consent before collecting personal data through non- essential cookies. For more information, including cookie retention periods, consult VENDIO's cookie management policy.

7. How VENDIO Protects Personal Data

VENDIO implements appropriate security measures to protect personal data from unauthorized access, alteration, disclosure, or destruction. Where possible, personal data is pseudonymized.

8. Sharing of Personal Data

As mentioned in section 2, the Platform facilitates exchanges between Buyers and Sellers. Personal data is exchanged through the Platform according to the instructions provided by the Buyer or Seller. The Platform may also link to third-party websites. VENDIO does not retain any data entered by the User on these external sites. Personal data may be shared with hosting partners, web content providers, marketing service providers, and subcontractors involved in service delivery, provided they comply with applicable data protection laws. VENDIO may also disclose personal data to comply with legal obligations or to protect its rights, property, or safety, or that of others.

9. Data Retention

VENDIO takes reasonable measures to ensure personal data is processed and retained only for the minimum period necessary for the purposes outlined in this Privacy Policy:

• Without a User Account:
  • Data from forms or communications: retained for 5 years from the last contact.
  • Other data: retained for 4 weeks.
• With a User Account:
  • Retained for 5 years after account deletion, except accounting data (10 years).
• For All Users:
  • Backups retained for 4 weeks.

10. Data Security and Transfer

VENDIO implements technical and organizational measures to protect personal data. Users must ensure they submit data securely. VENDIO does not transfer personal data outside the EU or to international organizations.

11. Data Management and Minimization

VENDIO ensures personal data is accurate and collected only as needed for the purposes outlined in this Privacy Policy. Users can modify inaccurate data at any time.

12. Data Subject Rights

Users have the right to access, modify, restrict, object to processing, erase, and transfer their personal data. These rights can be exercised by emailing contact@vendio.market. Users may also file complaints with the Luxembourg data protection authority: Commission nationale pour la protection des données..

13. Acknowledgment of the Privacy Policy

By using the Platform, Users acknowledge that they have read and agree to the terms of this Privacy Policy.

14. Changes to the Privacy Policy

VENDIO reserves the right to update this Privacy Policy at any time. Updates will be noted at the bottom of this page, and notifications sent to subscribed Users. Continued use of the Platform following changes indicates acceptance of the updated policy.